assessment ofapi supply chain duringgmp inspection · swissmedic • swiss agency for therapeutic...

Swissmedic • Swiss Agency for Therapeutic Products • Hallerstrasse 7 • 3012 Berne • Switzerland • www.swissmedic.ch

Assessment of API Supply Chain during GMP

Inspection

Swissmedic Training, 21-22 May 2019, Locarno

Georges Meseguer, Head Section Certificates and Licences, IBE / BW / Swissmedic

Agenda

● Introduction

● Practical Examples

● Key Points

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● Exploring best practices in evaluating the integrity of API supply chains

through the inspection of sites engaged in supply of active

pharmaceutical ingredients and fabrication of drugs in dosage form

● How to select, qualify and follow up API suppliers ?

● Who else is taking care of APIs from the supplier to the user ?

● RISK: What could turn wrong ?

● IMPACT OF RISK: What could be the consequences ?

● MITIGATION OF RISK : Which control points and tools to mitigate the

risk ?

Introduction

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● Most world sources of Protamine sulfate are located in Japan (sperm

of salmon fished off the Pacific coast next to Fukushima power plant)

Practical Example 1: Protamine sulfate

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● Since XVIIth century, quinine is extracted from Cinchona barks

● Cinchona barks is mainly sourced from DR of Congo

● DR of the Congo is politically instable

Practical Example 2: Quinine

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● There has been a strike of grain dock workers in Brazil.

o The strike impacted goods such as coffee, sugar, corn and soybean

o Possible impact on caffeine, amino acids, citric acid, ethanol,

carbohydrates, peptone, polysorbate

Pratical Example 3: Strike

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● Air freight: temperature control vs. security

● Air freight: what happens during transfer ?

● Ship freight: temperature and humidity control ?

Air and ship freight:

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● “A list of approved suppliers was provided but this list was not

managed as a Quality document”

● “In the form where all the information is collected, the address of the

manufacturing site was not specified “ : Manufacturer vs supplier;

What’s the difference ?

● “No system for evaluating new suppliers of APIs was available”

● “No documentation on history of GMP-conformity of current suppliers

of APIs was available“

Practical Example 4: some deficiencies

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● “The entry control sheet lists the items to be verified without giving any

specifications for these parameters. Further, this sheet does not show

the result of the entry control (acceptance or rejection of the batches)

with a dated signature of an authorized person“

● “ Absence of seal or broken seal not detected ” :

How far do seals provide adequate proof that containers are intact ?

● “Certificates of analysis were neither dated, nor signed and did not

show specifications”

● “ CoA did not display all tests requested by the customer “

● “ There was no original CoA, only copies “

Practical example 4: continued

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● Regulatory environment of the manufacturer

● Existence of GMP certificates/regulatory inspections

● Audit, questionnaire, pre-sampling and pre-analysis

● Trial batches

● Contract/Technical agreement – Notification of changes

● Quality follow up indicators

o API meets the analytical specification/trend analysis

o Integrity of shipment

o Deviations/complaints

● Identify the key players of the supply chain

● Need for back-up suppliers

● Regulatory: filing API manufacturers in the MA

Key Point 1: How to select and follow up API suppliers ?

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NB: Supplier ≠ original manufacturer

● Increasing number/complexity of links: more and more hand-offs, more

storage

● Transporters

● APIs needing specific type of transportation

e.g. cold temperature, secure transport (narcotics)

● Re-packer/re-labeller

● Irradiator, distributor

● Customs, storage during transport

● Virtual trader

Key Point 2: Who else is taking care of the APIs ?

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Anything / everything could go wrong !

● Loss of traceability

● Risk of contamination - Breach of the seals / Tampering (intentional or

not, by customs or…)

● Cargo theft (high value API, psychoactive APIs, …)

● Inadequate repacking (wrong packaging material or omitting inerting

gas…)

● Temperature and humidity control

o Air route, flight connection/stop over, holding time outside the

controlled temperature

o Sea route, ground transport

o Routes may change, delay in the transportation…

Key Point 3: RISK: What could turn wrong ? IMPACT: What could be the consequences ?

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● When sampling is done by the manufacturer (if acceptable): route of

shipment for sample and for batch may be different/ not representative

● Natural or industrial disaster or other crisis throughout the supply chain

(could impact the API and the starting material for the API)

o Hurricane, earthquake, flood

o Nuclear accident

o Major political crisis, war

o Strike (dockworkers…)

o Adulteration/falsification

● Site is found non GMP compliant by regulatory authorities (leading to

shortage)

● Site is subject to sudden increase of API orders (leading to overload)

Key Point 3: RISK: What could turn wrong ? IMPACT: What could be the consequences ?

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● Applying QRM to selection and follow up suppliers

● Having back up suppliers, filed in the MA

● Shorten the supply chain

● Handling of quality management, complaints, returns, recalls…

● Handling of re-packaging, re-labelling and holding of APIs

● Existence of a business continuity plan by each key player

● Having appropriate packaging materials

Key Point 4: MITIGATION OF RISK : Which control points and tools to mitigate the risks ?

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● Having refrigerated transport and data logger

● Checks of the API upon receipt

o ID of the containers (name and address of original manufacturer)

o Integrity of containers

o ID testing of the API: • which sampling plan: 𝑛 + 1 ? all containers ?

• which method: Chemical ? NIR/Raman

o Check transportation/customs documentation

o Authentic (original) CoA (11.40 of PIC/S GMP part 2)

Traceability - Integrity

Key Point 4: MITIGATION OF RISK : Which control points and tools to mitigate the risks ?

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